All India Organisation Of Chemists & Druggists (AIOCD) has made a representation to Smt. Nirmalaji Sitharaman, The Hon’ble Chairman – GST Council on  Problems and Suggestion for GST Yearly Return – GSTR 9, GSTR 9A and GSTR 9C. AIOCD has requested to postpone the last date for filing yearly returns in Forms GSTR 9, GSTR 9A and GSTR 9C or withdraw it completely, at least for the FY 2017-18.

Representation is based on Inputs from Representation made by AHILYA CHAMBER OF COMMERCE & INDUSTRY, INDORE

Text of their representation is as follows:-

To,
Smt. Nirmalaji Sitharaman
The Hon’ble Chairman – GST Council
5th Floor, Tower II, Jeevan Bharti Building, Janpath Road, Connaught Place, New Delhi-110 001

Sub : Problems and Suggestion for GST Yearly Return – 9, 9A and 9C

Dear Madam,

At the outset we must admit that the Council has been very responsive in realizing the difficulties of taxpayers from time to time but at the same time the plethora of notifications and amendments have left the entire stakeholder community of tax payers, tax consultants and even authorities in a state of utter confusion.

The latest example is the enormously lengthy yearly return forms 9, 9A & 9C. While taxpayers are finding it difficult to provide the required information, Chartered Accountants are also at a loss – despite clarifications – as to which data is to be filled where in so many fields. Local GST authorities are also not in a position to help. There is a strong case for a total withdrawal of this return for various reasons, some of which are enumerated hereunder:

i) Why Additional return : Yearly return is just a summary of all returns filed for the Year 2017 – 18. There were many difficulties already faced by Tax payers in filing those returns and it is an additional burden on, where they have to rework on all returns.

ii) Complexity of Yearly Return : Stake holders had expected a very clear and simple yearly return. They expected it to be user friendly. But for fetching all data in Yearly return, government has made it most This complexity will lead to more errors and mismatch of data.

iii) Rectification not allowed : Looking at complexity of yearly return, tax payer is bound to make mistakes.
Denying rectification in Yearly return is patently unjustified.

iv) HSN Code (8 digits) : GST law has allowed Tax payer to mention HSN code (Nil, 2 digits, 4 digits & 8 digits) as per Turnover or mode of operation. Tax payers dealing in India have to give maximum 4 digit of HSN We are surprised to note that, system is now asking 8 digit of HSN code in yearly return. How can the RP now provide it?

v) Auditors to decide Tax rate : In GSTR – 9C, provision has been made for auditors to verify the Tax rates of goods sold by taxpayers. Talking practically, how will auditors understand the chemistry of goods and decide what goods have been sold? How will they decide the rate of Tax? For understanding this, they need to study the items and give proper recommendation. This will not only take huge amount of time, but it will be herculean task to complete audit. Also, is there a guarantee that the auditor’s interpretation will be correct?

vi) EXCESS CREDIT UTILIZATION : Provision has been made for depositing of any tax liability that arises after audit in Form 9 C, but if there is excess credit in the taxpayer’s account, the same cannot be utilized. This is not only an extremely harsh and inequitable provision but speaks of the council’s mindset to collect revenue by even unfair means.

Other than the above, there are many other issues which we have attached along with this mail.

All told, there is a strong case for not only postponing the last date for filing yearly returns in Forms 9,9A and 9C but withdraw it completely, at least for the FY 2017-18. This will go a long way in achieving Prime Minister Shri Narendra Modi’s much promised “Ease of doing business’.

If the Council is very keen on burdening tax payers with this form to add to their already huge compliance, it may do so after making it less cumbersome, simpler, transparent and easy to comply with, from FY 2018-19.

———

On Problems and Suggestion for GST Yearly Return — 9, 9A and 9C

i) Government delay, Tax payer problem : Government took nearly 1.5 year to release yearly return (15th July 2017 to 31th Dec 2018). On top of that, GSTR – 2 A for data related to 2017 – 18 have been uploaded in May 2019. Offline tools related to GSTR – 9 and 9C were released in May 2019. Practically, Tax payers / Tax consultant have only 1 month to prepare complex yearly return. Enough time should be given to Stake holders to study return, Hand-on on system and prepare relevant software.

ii) Dual Audit and Rework of Complete data after 1.25 years of completion of year 2017 – 18 :
Government is aware that Income tax audit is already done in Apr – Sep 2018. All other statuary audit and government compliance has been done till October 2018. Going for GST audit in June 2019, is complete rework for stake holders. Recall of transaction done in 2017 – 18 is very difficult. On top of that, to expect perfect compliance after 1.25 year is too much.

iii) Amendment / Clarification in First year : Year 2017 – 18 was first year for GST . There were many lacunas and scope of improvement. With regular communication with stake holders, many problems were solved with enormous number of amendments and clarification issued by GST Council causing further confusion. Due to this, tax payers may have committed some mistakes, which may be revenue neutral mistakes. These mistakes are giving big impact in Annual return.

iv) Confusion in Yearly Return : Adding to complexity in yearly return, there is much confusion in many fields. We have studied the press release on OP June 2019 for clarification of different fields. Kindly note, description / pointers to each field are not sufficient. They are further confusing the stake holders. It is to be noted that proper suggestions / communication with stake holders has not been done. We request you to please discuss this with C.A’s or C,F.A’s, Trade & Industry representatives.

v) DRC – 03 Payment in CASH only, Not via ITC : GST Law mention that any payment which was not done in monthly return, has to be made at end of year. This can be due to errors. We want to ask council, why should DRC 03 payment be done in CASH only? Why cannot we make payment via ITC available with us?

vi) Mistake in Yearly Return : There are typing mistake in yearly return. For amendments (Liability or ITC) we can do in monthly returns from April 2018 to March 2019. But Portal is showing only April 2018 to Sep 2018. It should be amended immediately.

vii) Rectification not allowed : Looking at complexity of yearly return, tax payer is bound to make mistakes. Denying rectification in Yearly return is patently unjustified. It should be allowed.

viii) HSN Code (8 digits) : GST law has allowed Tax payer to mention HSN code (Nil , 2 digit, 4 digit, 8 digit) as per Turnover or mode of operation. For Tax payer dealing in India, have to give maximum 4 digit of HSN code. We are surprised to note that, system is now asking 8 digit of HSN code in yearly return. How can the RP now provide it?

ix) HSN Code for Inward Supply : Taxpayer receives inward supply from all types of taxpayers. He may receive supply from Tax payer whose turnover may be less than Rs.1.5 Cr. There is no mention of HSN code. How will Tax payer decide about the correctness of HSN code? Without fault of Taxpayer, he will be penalising for mistakes.

x) Fees to Auditors : Looking at complexity of Yearly return, GSTR — 9 and 9 C, lot of work has to be done. This complexity was not known at time of GST implementation. How will tax payer absorb this heavy fee? Under which head they will debit this fee? This fee has to be accounted for F.Y. 2017 — 18. But Income tax return has already been filed. Expenses can be disallowed by Income tax authority.

xi) Auditors to decide Tax rate : In GSTR — 9C, provision is made for auditors to verify the Tax rates of goods sold by taxpayers. Talking practically, how will auditors understand the chemistry of goods and decide what goods is sold? How will they decide the rate of Tax ? For understanding this, he need to study the items and give proper recommendation. This will not only take huge amount of time, but it will be herculean task to complete audit.

xii) 5 Types of Data : Due to extreme complexity of GST Law significant relaxation was given from time to time. There were few minor errors committed by Taxpayers due to less knowledge of law / amendment in law. If we properly study GST data of any taxpayer, there are 5 set of accounting data for any taxpayer.

a) Data As per GSTR —1

b) Data As per GSTR — 3 B

c) Data As per GSTR — 2 A

d) Data As per Taxpayer Books / Income Tax records

e) Data As per GST Law

Tax payer is not able to decide, which data should be kept in reference and prepare GSTR — 9 and 9 C.

xiii) GSTR — 2 A Data Mismatch : Due to some errors on portal and few errors by taxpayers, data in GSTR — 2 A is not shown. This is biggest problem in data compilation and matching. Why should Tax payer be penalised for errors on GST Portal and omissions by suppliers. This is against natural justice.

xiv) Portal Problems not rectified : GST Council / GST Network may refer our many representations regarding Portal problems. Many tax payers have filed GSTR — 1 in July and August 2017, but data is not reflected in GSTR — 2 A of recipients’. Instead of many tickets logged with department, still all problems are on same level. Government should solve problems first and then ask for yearly returns.

xv) ITC — 04 last date is 30/06/2019 : For Job work, ITC 04 has to be filled for 2017 — 18 till 30/06/2019. How will auditors, audit before filing of ITC 04 for same period?

xvi) GSP not ready with latest version : GSP are integral part of system. All returns are prepared by GSP like Tally on accounting systems. These data are then loaded in Offline tool or uploaded directly. Council may note that, GSP are not ready till now. How can Taxpayer manually prepare return without Software from Tally.

xvii) NON GST Supply / Exempt Supply : Much of data is to be filled for NON GST supply and exempt supply. There is lot of confusion on both heads. Please note that, both supplies does not involve any GST revenue. These data should be excluded from returns. We are making system and return more and more complex resulting in more errors.

xviii) Notices from Department (Can Department handle them) : Above all points indicate that there may be either very minor or significant mismatch in returns. GST Network is online system without human intervention. System does not recognize tax payer as per merits. System only recognizes Return mismatch which may be even 0.01%. Thus, may be crores of notices issued by system on filing of yearly returns, which will result in Chaos. While putting the taxpayer to extreme harassment it will also create huge amount of non productive work for department.

xix) GST PORTAL scalability (Still a problem) : GST Portal has not been stabilized till now. Looking at numbers of tax payers and amount of data to be uploaded / downloaded on Portal, we are certain, portal will collapse on final dates.

Download Representation in PDF Format (Official Copy)

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55 Comments

  1. ANIL MHETRI says:

    It’s totally burden on Owners/Traders/Businessmen
    And also additional work load to working staffs.

    Please don’t make too much complicated work.It must ease to all..

  2. B.BISWAS says:

    Please allow to revise option one time those who was filed and make some mistake on filed GSTR 9 Return because the said annual return filed first time and newly prepared and some complicity on GSTR9 Return.

  3. ARUN HABIB says:

    SIR/MADAM,
    MY ISSUE IS REGARDING THE OPTION TO BE PROVIDED TO THE BUYERS TO UPLOAD THE INVOICES MISSING WHEN SUPPLIERS DONT UPLOAD IN THEIR GSTR 1.
    OTHERWISE WE WILL LOSE THE ITC TO BE CLAIMED. ALSO REQUEST FOR EXTENTION OF DUE DATE FOR FILING ANNUAL RETURN FOR 17-18.

  4. Rajendar says:

    all above points raised by All India Organisation Of Chemists & Druggists (AIOCD), we as tax consultants facing problems with clients, especially difference arised between GSTR-3B and GSTR-2A.
    If the supplier not filed the invoice in GSTR-1, Recipient facing problem in matching input credit, in addition recipient become liable for acts of supplier as per GST Law. This is very Hercules.

  5. Ramalakshmi says:

    Above points are practical difficulties faced by every sector in Indian economy after introduction of GST era.Most terrible issue is Govt has not facilitated alteration or rectification of Filed returns. Even for GSTR-9 , there is no option of alteration or revised return facility.I request Honble Finance minster to consider practical difficulties of stake holders,take appropriate reasonable decision of extending return filing or to implement simplified return with hastlefree access to portal.

  6. krishnappa says:

    There is justification for extending the due date for filing GSTR 9 for 2017-18 as some of the informations sought in the return were not known to tax papers before hand so that proper records could be maintained. It will be a good gesture on the part of GST council to extend the due date and simply the format atleast for the first year (i.e. 2017-18).

  7. alok saxena says:

    Sir
    Pl make GST System simple & easy as told by our council as time it’s start but it’s very Difficult s to all persons.
    To day our tax system is not so easy to work without any consultants.pl open GST Help center free cost /or fixed charges of all work to help needed person .
    Now if we do away with the annual return and audit for F Y 2017-2018 and 2018-2019 by giving a final opportunity to dealers to compute their correct output, input and net liability of taxes due under GST for 2 years and discharge the taxes due, if any, by making the payments by 31-07-2019. And in case the dealers cannot do this, he ends up paying 2% interest per month and beyond that penalty of Rs………….. (to be determined by Government). And even after all this, if dealer is found to be in default, can be dealt with according to law. This seems to be more practical.

  8. viji says:

    instead of requesting time extension, it would be prudent to request for a simple one page summary annual return like a 3B format with minimum but most essential details. This can be followed only for the first year & later on the detailed 9/9c format can be considered. Being e new tax regime the first year was full of confusions & disruptions. If the formats are simple, no one would seek extension & by now all annual returns would have been available in the portal. Because the govt is insisting for a cumbersome, very detailed format this first return is still not in place. Govt needs to review its stand & simplify the format rather than extend time.

  9. Balamurugan says:

    Request the Honorable Finance minister to consider the withdrawal of GSTR 9 and 9C in view of many practical difficulties in reconciling the data of GSTR 1, 3B and 2A.

  10. DILIP says:

    I am doing accounts writing work for small business, and for one Register GSTIN holder facing problem since the 5th Oct 2017 is opt out from composition to regular but GST help desk not providing proper solution till the date even after more than 7 time tkt raised for the issue also i have submitted written application to the Asst. Comm as well as to Superintendent under the Bhiwandi comm.

  11. Ratnakar Annigeri says:

    GST 9 date must be extended along with option for revision till March 2020. Otherwise, so small traders will be penalized unnecessarily and will be forced to close down businesses. Being first year Govt must show good gesture to business community.

    June 16, 2019 at 9:06 am

  12. SANKAR KUMAR BANERJEE says:

    AS PER COMPUTED GSTR-9 WHICH IS GENERATED ,THERE ARE SOME PORTION ARE BLOCKED THAT’S WHY OUR UNUTILISED ITC & GST PAYMENT ARE LYING IN OUR CASH LEDGER & CREDIT LEDGER SO WHY WE ARE AGAIN THE PAYMENT OF GST . THE BUSINESS POSITION ARE TOTALY SICK AND NO SCOPE OF FURTHER PAYMENT. PLEASE GIVE US THE SIMPLE WAY TO FILE THE ANNUAL RETURN AS PER OUR AUDITED ACCOUNTS & OUR AUTHENTICATED RECORD WHICH WE CAN PRODUCE AS PER OUR ANNUAL RETURN , WE REQUEST TO OUR HONORABLE PRIME MINISTER & OUR HONOURABLE FINANCE MINISTER TO SOLVE THE PROBLEM.

  13. SANKAR BANERJEE says:

    THE FILLING OF GSTR-9 , THERE IS SO MANY DIFFICULTIES FOR UNUTILISED ITC , UNUTILISED PAYMENT OF GST WHICH LYING OUR CREDIT LEDGER AND ALSO CASH LEDGER FOR THE PERIOD 01.07.2017 TO 30.04..2018 . IN GSTR-9 THERE SOME PORTION ARE BLOCKED . IF BUSINESMEN CAN FILLED IF BLOCKED PORTION ARE OMITED SO EVERY TAX PRAYER CAN FILLED THERE RETURN AS PER THERE ACCOUNTS & RECORDS . SO REQUEST THE TEAM OF GSTIN AND OUR HONOURABLE PRIME MINISTER & FINANCE MINISTER SO WE CAN DO THE WORK ACCORDINGLY . AND EXTENT THE TIME AND BLOCKED PORTION ARE OMITED

  14. Shaibal Banerjee says:

    Sir /madam
    It is my humble request to extend the date of GSTR 9 or withdraw the same for the period 2017-18.We hope your earnest interference in ths regard.

  15. Pinakin Bhavsar says:

    Thanks for recommendation of extension of Annual Return for 2017-2018. But need to send request for Re-opening of TRAN-1 since Many Taxpayers didn’t get opening credit due to technical problem/ non awareness of portal.

  16. Akriz & Tabsha says:

    Is there any Annual Return in Income Tax to be filed ? the answer is NO, because it is only one return to be filed depending upon the source of income under direct taxes. SO when there is ONE NATION ONE TAX (GST) under indirect taxes, why the hell lot of returns in this. when the GST data is merged with Income tax data why not Direct & Indirect be merged to one tax. my dear government please play with the companies whose turnover is more than 500 to 1000 crores BUT not with the small traders & companies finally i can say catch the fishes of the sea instead of searching insects in the ponds.

  17. BSR KRISHNA says:

    IF THE GOVERNMENT CANCELLS ANNUAL GST RETURN FOR THE FIRST YEAR 2017-18 IT WOULD BE A VERY GOOD DECISION AND GOOD RELIEF.I ALSO SAY THAT ALL THE INFORMATION IS AVAILABLE ON THE CONCERNED FIRMS ACS.SO GOVERNMENT CAN RECHECK AND FINALIZE THE YEARLY WORK OF THE GSTR9.IF FURTHER INFORMATION IS REQUIRED THE CONCERNED AUTHORITIES CAN ASK THE FIRMS TO ANSWER PROPERLY TO THE RELAVENT QUERIES AND GET THEM SOLVED.

  18. MYANK GUPTA says:

    The monthly returns should be clubbed by the system itself to check the yearly liability or refund of the taxpayer. The Annual Returns are extra burden on all i.e. Assessees, CA’s, Tax Authorities etc.
    In case there is any difference in tax liability as per book and GST portal, the same would be well checked and identified by the auditor at the time of finalizing the yearly books.

  19. V Ramanathan says:

    In GSTR 2A, credits appearing twice against the same Invoice due to filing of GSTR 2 return for the month of July’17 before it was officially withdrawn. It is purely portal issue. Very difficult to convince auditor/ recipient of goods or services.

  20. Deepak says:

    Dear Prime Minister and Dear Finance Minister ~ Namaste.

    If you are not extend gstr9 due date than withdraw GST tax completely.
    Because we are not able to file gstr9 before 30 June 2019.

  21. Jitendra says:

    Yes, it should be widrawn, all business man, consultant are confused with several notification, update every day, today learning becomes yesterday’s thing. Go on studying everyday like final exam since introduction of gst law

  22. Venkat says:

    The above points raised by the AIOCD should be considered by GST council and should give relief to all by postponing or cancelling the filing annual return in terms of ease of doing business.

  23. mukesh parmar says:

    Dear Prime Minister and Dear Finance Minister ~ Namaste.
    The annual return and audit under GST for F Y 2017-2018 (7 Months) should be done away with. It will only result in waste of time n energy of both business man and Government. already 15 months have gone by from 31-03-2018. The accounts were already prepared. Since, the forms and formats under GST were not available at that time, the reports can not be generated from the accounts for audit or annual return. It involves extra work and time. As it is compliance burden has gone up under various existing laws.

    We have to walk the path together with ease to make this a Good and Simple Tax(As our beloved Prime Minister had launched it with this moto) but today it has really become more entangled like the spider web.

    Further, for the F Y 2018-2019 also the accounts have been prepared and are in the various stages of finalisation. The forms of GST audit and annual return have been recently published and seminars are still being conducted to educate the dealers. And the department is also finding it short to explain to dealers.

    Under the circumstances it is wise to drop the annual return and audit for F Y 2018-2019 too.
    However, the same can be undertaken from F Y 2019-2020. To make this possible the Government should come up with the required formats of the forms and reports before 30-06-2019, so as to enable the dealers to maintain the accounts to generate the reports for the same. This seems tobe more wise and practical and in line with natural justice.

    Now if we do away with the annual return and audit for F Y 2017-2018 and 2018-2019 by giving a final opportunity to dealers to compute their correct output, input and net liability of taxes due under GST for 2 years and discharge the taxes due, if any, by making the payments by 31-07-2019. And in case the dealers cannot do this, he ends up paying 2% interest per month and beyond that penalty of Rs………….. (tobe determined by Government). And even after all this, if dealer is found tobe in default, can be dealt with according to law. This seems tobe more practical.

    We are with you Sir and Madam, and like to tread this path in simplicity. Hence, one more request. Please consult the professional and business men and various state Government to simplify the GST and make it more friendly. One should be at ease of doing business.

    Let us walk this path together, hand in hand, to reach our goals together for a Vibrant Nation. We are sure to see Lot of changes on the Horizon under your leadership in the days to come. One Nation One tax is our dream, let us realise it together.

    Thanking you in advance.
    Warm Regards.
    Mukesh.

    1. MALLIKARJUNA K says:

      Thank You, So much for your Representation to our Proud and Honorable Finance Minister. And also My Humble Request that Withdrawn FY 2017-18 and 2018-19 also .

  24. SHARAN says:

    Really this are valuable points to be considered by council,as we are facing many errors and mistakes, its highly difficult to match with financials. There are many grouping and schedules are done and matching with each and every details is difficult in this scenario.

  25. Deepak says:

    I requested to all CA, advocates and GST Practioner.
    Plz not file any gst return upto govt not extend gstr 9 date for atleast 6 month.
    Because itr and audit due date are also come.
    Plz not file any gst reutrn.

  26. Ravi says:

    DUE DATE OF FILING MUST BE EXTEND AND GST ANNUAL RETURN LIKE PREVIOUSLY WE ARE FILING VAT-240, sales as per books and purchase as per books the difference tax payable or refund.If department find any mismatch in any case they raise a notice to produce books of accounts.

    1. Sunil Rahwani says:

      First of all the annual Return to b withdraw completely or otherwise it should be like VAT annual Return where we can put figures as per our final data which we submitted while Filling of IT Return

  27. INDRAKUMAR says:

    Being first year 2017-18 GSTR 9A/9C should be withdrawn. Cumbersome return and lot of confusion n tallying GSTR 2A. It is against ease of doing business. Well represented. Govt should consider this. Others also should represent.

    1. TARUN says:

      YES GSTR 9 SHOULD BE COMPLETELY WITHDRAWN FOR THE YEAR 2017-18 AND PROPOSED FOR MANUAL ASSESSMENT FOR THIS YEAR. AND, MOREOVER, IF GSTR 9 IS COMPULSORY FOR REST YEARS THEN GIVE THE OPTION OF REVISE RETURN FOR 3B AND R1 IN SAME MONTH LIKE IN VAT RETURNS

  28. DD Verma says:

    on the practical grounds, I appreciate to AIOCD for representing major issues and difficulties of GSTR-9, 9C to the Hon’ble FM of India.
    I’m also willing to writ them with the same issues along with request to give an clarification for EOUs that “An EOU responsible for filling APR annual return, Quarterly return and customs returns, then Then how many returns are needed for EOUs in trems of “Ease of doing business”, is it called Ease of doing business.

  29. Surender Rattan Sharma says:

    Their is many invoices left in GST 3B GSTR1 and 2A . even we are facing the problems from portals. So its humble request to give the chance to correct the mistake and file accurate return. so Extend the date of filing Annual Return and I think its not ease to ding the business. Its very difficult for Businessman even professionals.

  30. Pradeep says:

    Yes Correct.

    For Job work, ITC 04 has to be filled for 2017 — 18 till 30/06/2019. How will auditors, audit before filing of ITC 04 for same period?
    and
    GSTR2A matching biggest problem

    Request the Honorable Finance minister to consider the withdrawal of GSTR 9 and 9C in view of many practical difficulties in reconciling the data of GSTR 1, 3B and 2A.

  31. K.Gururaja Rao says:

    The above said problems are correct and portal should be flexible since it’s new one rectification should be allowed

  32. GURUMURTHY says:

    ITC as per 2A downloaded in Excel is not matching ITC shown in the Comparitive statement ( Both are of GSTN ) only. Cases are there, Sales Invoices properly filed in GSTR-1 are not autopopulated in 2A. May be more issues founf by others. GSTR-2A matching in large data entitities may be difficult for Lord Brahman also.

  33. HIREN says:

    GSTR 9 IS EXTRA BURDEN OF CA AND ACCOUNTANT FEES, AND TIME CONSUMING , NOT POSSIBLE FOR SMALL TRADERS, THIS EVER BIG MISTAKE BY FINANCE MINSTRY

  34. MUKHERJEE says:

    its very good points raised by All India Organisation Of Chemists & Druggists (AIOCD) regarding GSTR-9. It is also note that balance sheet of the 2017-18 was completed and submitted at every compliance cell. So many practical difficulties in reconciling the data of GSTR 1, 3B and 2A. and for this it should be withdrawn completely, at least for the FY 2017-18.

  35. S.Lakshminarasimhan says:

    GST PORTAL scalability (Still a problem) : GST Portal has not been stabilized till now. Looking at numbers of tax payers and amount of data to be uploaded / downloaded on Portal, we are certain, portal will collapse on final dates. Eventhough Most of the Academy earning by conducting Smeniors. Auditors only the benefieroes. Institutions like Engg colleges earning without proper eduction.

    1. vswami says:

      Concluding remarks< seem to mirror the 'reality', nothing but the reality?!

      A Follow-on…..this timee it is the turn of …

      a Pick:
      ……
      "vi) EXCESS CREDIT UTILIZATION : Provision has been made for depositing of any tax liability that arises after audit in Form 9 C, BUT IF THERE IS EXCESS CREDIT IN THE TAXPAYER’S ACCOUNT, THE SAME CANNOT BE UTILIZED. , . This is not only an extremely harsh and inequitable provision but speaks of the council’s mindset to collect revenue by even unfair means."……

      FONT -to matrk an unclear area; the imact on 'supllier' (n case that refers to 'taxpayer') and in turn, if were any, on 'consumer' is crying for clarity ?!

      OVER to ….

  36. Sanjay kushwaha says:

    GSTR2A matching biggest problem . govt to allow to traders make amendement in GSTR 1 ONCE MORE TIME FOR F.Y. 2017-2018 SO THAT WE CAN RECONCILE OUR PURCHASE AND ITC WITH GSTR 2A . DUE DATE TO BE EXTEND FOR 2-3 MONTH WITH GSTR1 AMENDMENT

  37. JITENDER KUMAR RANKA says:

    Well represented by AIOCD.

    Government is planning its portal based invoicing by tax payers above 50 crores yearly turnover. This should not be taken further. It will increase work for tax payers and also create confusions.

    Further it is for sure that government system for generating invoices is not going to work at all and it will create double work for tax payers. IT IS GOING TO COMPLICATE THE WORK FOR TAX PAYERS.

    Government, please let the tax payers make their invoices and upload the monthy/quarterly returns.

    Just leave the idea of invoicing though portal. Government has performed the worst on GST portal. Please do not think of further complications imposing invoicing thorugh portal.

    Government please do not create situation of anarchy. Do not create situation where people start disregarding governement and stop businesses. Do you want that???

  38. Nagesh says:

    Rightly represented.
    Request the Honorable Finance minister to consider the withdrawal of GSTR 9 and 9C in view of many practical difficulties in reconciling the data of GSTR 1, 3B and 2A.
    Atleast the business community will be happy if done with GSTR 9 alone since tax liability if any is appearing on the portal, which can be paid if correct on the basis of returns filed by the assessees themselves.

  39. KISHORE GANDHI says:

    its very good points raised by All India Organisation Of Chemists & Druggists (AIOCD) regarding GSTR-9, these all are face when we are going to work practically…PLEASE ALSO RAISE THE POINT OF TRANS.-1

    1. Sudheer Shenoy says:

      GST 9 date must be extended along with option for revision till March 2020. Otherwise, so small traders will be penalized unnecessarily and will be forced to close down businesses. Being first year Govt must show good gesture to business community.

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